This page is part of our public exclusion list — a transparency tool that shows which companies we screen out and why. It is not investment advice, and it is not an accusation. But it is subject to change as our understanding of the facts evolves.
Aon Corporation paid $16.3M in combined DOJ/SEC FCPA penalties (December 2011) for improper payments across seven countries between 1983-2007. Subsidiaries made over $3.6M in bribes to secure or retain insurance business in Costa Rica, Egypt, Vietnam, Indonesia, UAE, Myanmar, and Bangladesh. Payments fell into two categories: training/travel/entertainment for government-owned client employees, and direct payments to third-party facilitators. SEC disgorgement totaled $14.5M; DOJ criminal fine was $1.76M. The breadth of jurisdictions and 24-year timespan reflect deeply embedded corrupt practices across the global insurance brokerage.
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The Naughty List
A digest of changes to our exclusion list — new additions, removals, and the evidence behind them. We review the list continuously as new evidence surfaces.
Companies appear on our exclusion list based on our investment judgment — not because they've done anything illegal. This is a difference of values and opinion, not an accusation of wrongdoing. Exclusion does not constitute a recommendation against investing in any company, and absence from the list does not constitute a recommendation to invest.
This information is provided for educational and transparency purposes only and should not be relied upon as investment advice. Data is drawn from independent watchdogs, NGOs, government registries, and Ethical Capital's ongoing research — see Research Sources for the full list.
Ethical Capital LLC is a state-registered investment adviser in Utah (CRD #316032). Registration does not imply a certain level of skill or training.